MLR stands for Money Laundering Regulations, which are a set of legal requirements designed to prevent businesses from being used to launder money or finance terrorism. In the UK, these regulations are overseen by HMRC, and professional bodies like ICB.
Legal Obligation – Bookkeepers must comply with MLR to avoid fines, penalties, or even criminal charges. If you’re offering bookkeeping services, you should be supervised by a recognised professional body.
Client Due Diligence (CDD) – Bookkeepers are required to verify their clients' identities, understand the nature of their business, and assess the risk of money laundering. This includes:
Suspicious Activity Reporting (SAR) – If you spot anything unusual, such as large unexplained cash transactions or a client refusing to provide information, you may need to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).
Maintaining Records – MLR regulation enforces the obligation to keep records of client due diligence checks and transactions.
Protecting Your Business & Reputation – Compliance with MLR helps safeguard your practice from being unintentionally involved in financial crime, which could harm your reputation and ability to trade.
Members with an ICB Practice Licence are automatically supervised by ICB under the MLRs. This means that you need to comply with MLR and ICB requirements. The ICB team is here to support you and can be contacted directly 8:30 - 5:30 Monday - Friday. We also provide regular webinars and updates to keep you in the know.
The ICB AML To-Do List is the perfect place to start!
Prior to awarding you a licence we will invite you to a virtual meeting with one of our AML Officers so that we can approve you and any of your Beneficial Owners, Officers or Managers (BOOMs). We will use this opportunity to discuss your practice set-up and AML obligations and you will have the chance to ask any questions you have about the requirements of the MLRs.
The ICB professional Services Team are super helpful
ICB supervised members must comply with the requirements of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the 2017 Regulations as amended by The Money Laundering and Terrorist Financing (Amendment) Regulations 2019), hereafter referred to as the MLRs), the Proceeds of Crime Act 2002 (POCA) and its amendments and the ICB Professional Conduct Regulations (PCR).
To comply with Anti-Money Laundering (AML) regulations and prevent illegal activities like money laundering, your practice must:
Understand the Risks
Conduct a comprehensive assessment of your practice to identify risks related to money laundering, terrorist financing, and proliferation financing.
Implement Policies and Procedures
Create, maintain, and regularly update policies and procedures to manage and reduce the risks identified in your risk assessment.
Appoint a Responsible Officer
Assign a Money Laundering Reporting Officer (MLRO) to monitor for suspicious activities. If necessary, the MLRO must file a Suspicious Activity Report (SAR) with the National Crime Agency (NCA).
Train Your Team
Provide training for relevant staff to help them recognize AML risks, warning signs, and suspicious activities.
Verify Clients and Monitor Activity
Perform customer due diligence (CDD) by assessing client risks, verifying their identity, and, where needed, checking the source of their funds. Adapt the level of checks based on each client’s risk level.
Keep Accurate Records
Keep documents and records, including CDD information, for five years after your relationship with a client ends or a transaction is completed.
Report Discrepancies
Notify the relevant authorities (e.g., the PSC Register, Trust Registration Service, or Register of Overseas Entities) of any significant discrepancies that may relate to money laundering or similar activities.
Register as a Trust and Company Service Provider (TCSP)
If your practice offers TCSP services, inform ICB so you can be added to HMRC’s TCSP Register. You cannot provide these services unless registered.
Approve Key Personnel
Apply to ICB for approval of your Beneficial Owners, Officers, and Managers (BOOMs). Each BOOM must provide evidence, such as a Basic Disclosure Certificate, to confirm they have no relevant convictions listed in Schedule 3 of the AML regulations.
These steps ensure your practice complies with legal requirements and contributes to the fight against financial crime.
ICB must check that supervised practices comply with Regulation 26 and that all beneficial owners, officers and managers (BOOMs) do not have a relevant criminal conviction.
ICB can only approve a BOOM if we have received a basic criminal record check certificate for them.
Every newly appointed BOOM must obtain a criminal record check at the time they become a BOOM and provide it to us for approval.
ICB supervised members must comply with the requirements of the:
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If you believe a practice supervised by ICB is breaching the Money Laundering Regulations, you can raise your concern confidentially.
0203 405 7581
If you come across a bookkeeper or bookkeeping practice, that does not appear to be supervised under the Money Laundering Regulations or appears to be ignoring the regulations and isn’t supervised by ICB you can contact the MLR Central Intervention Team:
You need only have one AML supervisor. If you are a member of another HM Treasury appointed supervisor, such as ICAEW or ACCA, please forward a copy of supporting documents to aml@bookkeepers.org.uk
As an ICB member in practice you are still required to hold a Practice Licence even if you have an alternative AML supervisor.
ICB publishes an annual report as required by The Money Laundering and Terrorist Financing (Amendment) Regulations 2019. The report contains details of the measures taken by ICB to carry out its role as a professional body supervisor.
